Evaluation of the 2018 EIA report for the Vung Ang II Thermal Power Plant Project (28 April 2020)

Evaluation of the 2018 Environmental Impact Assessment (EIA) Report For the Vung Ang II Thermal Power Plant Project By Mark Chernaik, Ph D Heidi W Weiskel, Ph D Staff Scientists Environmental Law Alli[.]

Evaluation of the 2018 Environmental Impact Assessment (EIA) Report

For the Vung Ang II Thermal Power Plant Project

By

Mark Chernaik, Ph.D

Heidi W Weiskel, Ph.D

Staff Scientists Environmental Law Alliance Worldwide

April 2020

Summary: In September of 2018, the Vung Ang II Thermal Power Joint Stock Company (VAPCO) issued an updated Environmental Impact Assessment Report for the Vung Ang II Thermal Power Plant Project (EIA Report) 1 Dr Mark Chernaik has more than twenty years of experience evaluating the adequacy of EIAs for thermal power projects Dr Heidi Weiskel, is an

experienced marine ecologist Our opinions were requested about whether the 2018 EIA Report fulfills basic requirements of internationally-accepted best practices for informing decision- makers and stakeholders about the potential environmental impacts of the proposed project

We conclude that the 2018 EIA Report:

• Failed to examine alternatives that prevent or minimize adverse environmental

impacts of the proposed thermal power plant;

• Used the wrong choice of an air pollutant dispersion model that renders

meaningless predictions of air quality impacts;

• Applied weaker emission standards for the project than those used

internationally;

• Allowed continued wet handling of ash contrary to international guidelines;

• Allowed discharge of thermal effluent in excess of international guidelines; and

• Erroneously dismissed potentially significant impacts to marine species

Below, we address each of these issues in detail

1 The EIA Report lacks an assessment of project alternatives

EIAs are a critical planning tool for any project A central purpose of the process is to identify alternatives for meeting the purpose of a project in a manner that minimizes its environmental and social impacts The basic purpose of a thermal power plant project is to provide electrical energy Therefore, consideration of alternative means of providing the electrical energy, including renewable energy sources such as utility-scale solar or wind projects, must be part of

an EIA for a proposed thermal power plant This concept is enshrined in guidelines that apply

to this project According to the Japan Bank for International Cooperation (JBIC):

“1 Environmental and Social Considerations Required for Funded Projects

In principle, appropriate environmental and social considerations shall be undertaken,

1 Japan Bank for International Cooperation 2018 Environmental Impact Assessment Report for the Vung Ang II Thermal Power Plant Project (2018 EIA Report)

https://www.jbic.go.jp/en/business-areas/environment/projects/page.html?ID=61715&lang=en

according to the nature of the project, based on the following:

(1) Underlying Principles

• Environmental impact which may be caused by a project must be assessed and

examined from the earliest planning stage possible Alternative proposals or

mitigation measures to prevent or minimize adverse impact must be examined,

and the findings of such examinations shall be incorporated into the project plan:

[…]

(2) Examination of Measures

Multiple alternative proposals must be examined to prevent or minimize adverse impact and to choose a better project option in terms of environmental and social considerations In examination of measures priority is to be given to the prevention of environmental impact, and when this is not possible,

minimizing and mitigating impact must be considered next.”2

The Vung Ang II Thermal Power Plant Project has a rated capacity of 1320 MW (2 x 660MW)

and as such can be expected to emit more than 10 million metric tons per year of carbon

dioxide, a greenhouse gas The requirement for an assessment of renewable energy

generation alternatives, (e.g., utility-scale solar and wind projects) is heightened because such

projects emit copious quantities of greenhouse gases, the negative environmental and social impacts of which are well-documented According to International Finance Corporation (IFC) Performance Standard 3 (Resource Efficiency and Pollution Prevention), the following principles apply:

Greenhouse Gases

“7 In addition to the resource efficiency measures , the client will consider

alternatives and implement technically and financially feasible and cost-effective

options to reduce project-related GHG emissions during the design and operation of the

project These options may include, but are not limited to, alternative project

locations, adoption of renewable or low carbon energy sources, sustainable

agricultural, forestry and livestock management practices, the reduction of fugitive emissions and the reduction of gas flaring.”3

2 Japan Bank for International Cooperation Guidelines for Confirmation of Environmental and Social Considerations (January 2015) pp 18-19 (emphasis added)

https://www.jbic.go.jp/wp-content/uploads/page/2013/08/36442/Environemtal_Guidelines2015.pdf

3 International Finance Corporation (IFC) 2012 Performance Standard 3: Resource Efficiency and Pollution

Prevention 5 pp pp 1-2 (emphasis added)

In violation of JBIC Guidelines for Confirmation of Environmental and Social Considerations and

IFC Performance Standard 3, an assessment of renewable energy generation alternatives is

absent from the 2018 EIA Report for the Vung Ang II Thermal Power Plant Project

This failure is a fatal flaw of the 2018 EIA Report because a transformation is changing

electricity markets in Vietnam, with solar and wind projects rapidly providing inexpensive and

clean electricity generation in a manner that is filling energy demand with minimal

environmental and social impacts

A report published in March of 2020 by the Carbon Tracker Initiative (CTI) finds that new

renewables are cheaper than new coal in all major markets today According to CTI:

“In Powering Down Coal: Navigating the economic and financial risks in the last years of

coal power published in 2018, we found that declining renewable energy costs and

existing carbon and air pollution regulations were already undermining coal as the cost option for power generation Due to price deflation of renewable energy, we

least-concluded that coal generation would become uneconomic in both absolute and

relative terms Regarding the latter, we anticipated that by 2025 at the latest,

investments in new renewables would beat new coal investments in all markets Using

updated data from publicly available sources, we now believe these conclusions are too conservative Our analysis finds that the LCOE [levelized cost of electricity] of renewable energy is cheaper than the LCOE of coal in all major markets today.”4

To illustrate its finding, the CTI report shows how today in 2020 new wind projects in Vietnam have an levelized cost of electricity (LCOE) of $58 per megawatt-hour ($/MWh), substantially below the LCOE of $69/MWh for new coal-fired plants According to section 1.4.8 of the 2018 EIA Report, the total budget for the Vung Ang II Thermal Power Plant Project is about $2 billion

Under circumstances in which the LCOE of new solar and wind energy generation is less

expensive than the LCOE for a new coal-fired plant, it should be presumed that utility-scale solar

and wind projects in Vietnam will meet the basic purpose of a new coal-fired power plant with far less environmental and social impact and fewer economic risks

These are basic facts that VAPCO should have known prior to its issuance of the EIA Report for the Vung Ang II Thermal Power Plant Project in 2018 In June of 2018, the Green Innovation and Development Centre (Green ID) published a report showing that the LCOE of both ground-mounted solar installations and wind turbines in Vietnam would be at or below the LCOE of

https://www.ifc.org/wps/wcm/connect/1f9c590b-a09f-42e9-968c-c050d0f00fc9/PS3_English_2012.pdf?MOD=AJPERES&CVID=jiVQIwF

4 Carbon Tracker Initiative 2020 How to waste over half a trillion dollars: The economic implications of

deflationary renewable energy for coal power investments (emphasis added)

https://carbontracker.org/reports/how-to-waste-over-half-a-trillion-dollars

ultra-supercritical coal-fired power plants by the year 2020.5 Later in 2018, the CTI published a report concluding that in Vietnam by 2020:

“… it will be cheaper to invest in new solar PV than new coal and 2022 for onshore wind This represents the first inflection point when new investments in coal capacity become economically uncompetitive relative to new investments in renewable energy These changing cost dynamics call into question over 30 GW or $40 bn of planned coal

investments in Vietnam and the long-term role of the existing fleet to deliver an

economic return to investors.”6

The EIA process should have included an assessment of alternatives that incorporated this critical information

2 The wrong model is used to predict air quality impacts

Coal-fired power plants emit large quantities of air pollutants, including particulate matter (PM), sulfur dioxide (SO2) and nitrogen oxides (NOx) In the 2018 EIA Report, VAPCO estimates that the proposed Vung Ang II Thermal Power Plant would emit 56.9 grams per second of PM,

227 grams per second of SO2, and 478 grams per second of NOx At full operation of 8760 hours per year, this equates to emissions of 1794 metric tons per year of PM; 7177 metric tons per year of SO2; and 15074 metric tons per year of NOx

These large quantities of emissions have the potential to increase concentrations of pollutants

in ambient air to an extent that adversely impacts human health For this reason, it is

international best practice to quantitatively predict how pollutant emissions from a proposed thermal power plant might impact ambient air quality According to the United States

Environmental Protection Agency:

“In evaluating the potential impacts of a power generation or transmission project on ambient air quality, prediction should be made to determine the extent to which

ambient air quality standards may be compromised The predictions should assess the likelihood of air pollution from the plant, dumps, and materials storage and handling facilities, identify the areas of maximum impact, and assess the extent of the impacts at these sites Although analytical approaches can be used, international experience

indicates that numeric modeling is the most appropriate method to evaluate the

impacts of a power generation or transmission project on air resources Quantitative

5 GreenID 2018 "A blueprint for Vietnam's Clean Energy Future."

http://en.greenidvietnam.org.vn//app/webroot/upload/admin/files/Khuyen%20nghi%20chinh%20sach%20Eng_co mpressed(1).pdf

6 Carbon Tracker Initiative 2018 Economic and financial risks of coal power in Indonesia, Vietnam and the

Philippines

philippines/

https://carbontracker.org/reports/economic-and-financial-risks-of-coal-power-in-indonesia-vietnam-and-the-models can be used to calculate contaminants in air and to compare the results to numerical air quality standards

At the facility level, impacts should be estimated through qualitative or quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models to assess potential ground level concentrations Local atmospheric, climatic and air quality data should be applied when modeling dispersion.”7

Similarly, according to the IFC:

“At facility level, impacts should be estimated through qualitative or quantitative

assessments by the use of baseline air quality assessments and atmospheric dispersion models to assess potential ground level concentrations Local atmospheric, climatic, and air quality data should be applied when modeling dispersion, protection against

atmospheric downwash, wakes, or eddy effects of the source, nearby13 structures, and terrain features The dispersion model applied should be internationally recognized, or comparable Examples of acceptable emission estimation and dispersion modeling approaches for point and fugitive sources are included in Annex 1.1.1 These approaches include screening models for single source evaluations (SCREEN3 or AIRSCREEN), as well

as more complex and refined models (AERMOD OR ADMS) Model selection is

dependent on the complexity and geomorphology of the project site (e.g mountainous terrain, urban or rural area).”8

As detailed below, the 2018 EIA Report for the proposed Vung Ang II Thermal Power Plant fails

to accurately assess potential ground level concentrations because of its wrong choice of an atmospheric dispersion model Pages 156 and page 209 of the 2018 EIA Report state that VAPCO used a Japanese air pollutant dispersion model (Ministry of Economy, Trade and

Industry Low Rise Industrial Source Dispersion Model METI-LIS Model Ver 2.02) for predicting air quality impacts of the proposed Vung Ang II Thermal Power Plant: Pages 156 states:

“Dự báo phát thải bụi và khí thải qua ống khói được sử dụng mô hình Metilis với các thông số đầu vào về khí tượng thuỷ văn, địa hình, yếu tố ảnh hưởng đến khí quẩn, và không gian lưới tiếp nhận được mô tả như sau: …

Địa hình xung quanh có thể tác động đáng kể đến mức độ phân tán của khói Cao

độ của địa hình vượt 10% cần phải được bao gồm trong mô hình và trong biên chiều cao của của địa hình đồi Do đặc trưng địa hình đồi núi khu vực xung quanh, số liệu về địa hình được tính đến trong mô hình phân tán

Có thể thấy rằng khu vực xung quanh vị trí dự kiến của nhà máy có cao độ đáng

kể, trên 360m về phía bắc của thôn Tây Yên và phía nam của nhà máy và dao động trong khoảng 240m đến 310m về phía tây nam của nhà máy (Hình 3.3) Dữ liệu chi tiết về địa hình sử dụng cho mô hình được trình bày trong Phụ lục 3.6

Vì nhà máy được đặt tại bờ biển và dưới 50% diện tích khu vực trong bán kính 3km của ống khói được dùng làm khu thương mại, khu dân cư và sản xuất công nghiệp, do đó, các tham số tính toán được đặt trong mô hình ở điều kiện khu vực nông thôn

sẽ không bị ảnh hưởng bởi khí quẩn từ các khu nhà

Với chiều cao ống khói khoảng 210m, chiều cao ống khói theo tiêu chuẩn kỹ thuật, được tính bởi mô hình và dựa trên hướng của các khu nhà xung quanh, không nhỏ hơn chiều cao thật của ống khói, do đó, các khu nhà sẽ không ảnh hưởng đến nồng độ phát thải tại mặt đất.”

ENGLISH TRANSLATION

“The METI–LIS model is used to forecast dust and exhaust gas emissions from stacks with the input parameters on meteorology and hydrology, topography, factors affecting the trapped air and receiving grid spaces as follows: …

smoke-Topography

The surrounding terrain may have significant impacts on the dispersion of smoke Terrain elevation of over 10% must be included in the model and in the height boundary of the hilly terrain Considering the hilly terrain in the

surrounding area, topographical data are taken into account in the dispersion model

It can be seen that the area around the proposed location of VA2 Plant has significant elevation of over 360 meters to the north of Tay Yen Village and to

the south of the Plant The elevations range from 240 meters to 310 meters to the southwest of the plant (Figure 3.3) Detailed data on the terrain used for the model are presented in Appendix 3.6

The Plant is situated on the coast and less than half of the area of no more than

3 kilometers of the smoke-stacks is for commercial, residential and industrial production purposes so the calculation parameters are set in the model applied for rural areas

Trapped air in residential clusters

Surrounding residential clusters may affect the dispersion of smoke, causing the phenomenon known as trapped air Any buildings that are higher than a third of the height of emission sources can possibly affect the dispersion of exhaust smoke The height of smoke-stacks compliant with technical regulations ensures that exhaust smoke is not influenced by the air trapped in residential clusters

The height of the Plant’s smoke-stacks is 210 meters which complies with technical regulations It is calculated based on a model and directions of surrounding residential clusters Therefore, the clusters will have no impacts on ground-level emission concentrations.”9

Page 209 of the 2018 EIA report states:

“Mô hình METI_LIS: Trong dự báo lan truyền ô nhiễm không khí, báo cáo đã sử dụng mô hình METI-LIS được xây dựng bởi Bộ Kinh tế-Thương mại và Công nghiệp Nhật Bản (Ministry of Economy, Trade and Industry - METI) từ năm 1996 Mô hình lan truyền METI-LIS là mô hình dạng Gauss (Gaussian dispersion model) được hình thành trên cơ sở

mô hình Industrial Sources Complex ISC của Ủy ban Bảo vệ Môi trường Mỹ

(Environmental Protection Agency- EPA) ISC là mô hình mang tính pháp quy ở Mỹ và được sử dụng rộng dãi trên thế giới

METI đã phát triển, đưa vào sử dụng mô hình METI-LIS, khi vấn đề nhiễm bẩn không khí được đưa vào Đạo luật Ngăn ngừa Ô nhiễm Không khí (Air Pollution Prevention Act ) tại Nhật Bản Hàng lọat các thực nghiệm trong ống khí động và trên hiện trường với mô hình đã được tiến hành dưới sự bảo trợ của METI, phiên bản pilot METI-LIS đã được đưa

ra năm 2001 Phiên bản 2 của METI-LIS 2.02 năm 2005 - với nhiều cải thiện trong trong phần mềm cả về nội dung lẫn hình thức, với nhiều công cụ thân thiện hơn cho người sử dụng

9 VAPCO 2018 Vung Ang II Thermal Power Plant Project Environmental Impact Assessment (2018 EIA Report) Chapter 3: Evaluation and Forecast of the Environmental Impacts of the Project 130 pp for Chapter 3 pp 157-

158

METI-LIS là phần mềm được sử dụng rộng rãi để nghiên cứu, đánh giá lan truyền chất ô nhiễm từ các NMNĐ ở Nhật Bản (Phụ lục 3.7).”

METI has developed and put into use the METI-LIS model, when air pollution is

introduced into the Air Pollution Prevention Act in Japan A series of aerodynamic and field experiments with models were conducted under the auspices of METI, a pilot version of METI-LIS was launched in 2001 Version 2 of METI-LIS 2.02 in 2005 - with many improvements in software both in content and appearance, with more user-friendly tools

METI-LIS is a widely used software to study and assess the spread of pollutants from thermal power plants in Japan (Appendix 3.7).”

Contrary to the claim made in the 2018 EIA Report, METI-LIS is not a preferred or

recommended air pollutant dispersion model of the U.S EPA for predicting air quality

impacts from a proposed industrial facility The only two preferred or recommended air

pollutant dispersion models for land-based polluting facilities are the AERMOD Modeling System and the Complex Terrain Dispersion Model Plus Algorithms for Unstable Situations (CTDMPLUS).10

More importantly, METI-LIS was the wrong choice of a pollutant dispersion model because of the complex terrain in which the proposed Vung Ang II Thermal Power Plant is situated The proposed location of the facility is on the shoreline within a few hundred meters of hills that rise to more than 300 meters (see Google Earth satellite image below dated 20 April 2019) This topography is highly likely to trap air pollutants emitted from the proposed power plant,

especially when winds are calm and shortly after sunrise when cooler sea and land surfaces reduce the height of mixing layer into which pollution plumes from a stack can disperse

10 U.S EPA Support Center for Regulatory Atmospheric Modeling, Air Quality Dispersion Modeling - Preferred and Recommended Models

https://www.epa.gov/scram/air-quality-dispersion-modeling-preferred-and-recommended-models

The height of the proposed combined stacks that emit pollutants from the Vung Ang II Thermal

Power Plant is 210 meters, which is lower than the height of the nearby hills When a polluting

facility is located near to hills higher than its stack, then the facility is located in what air

pollution modeling experts call complex terrain According to the published operation manual

for METI-LIS, this air pollutant dispersion model should NOT be used for facilities located in complex terrain, but only for facilities in simple terrain.11

11 Research Center for Chemical Risk Management National Institute of Advanced Industrial Science and

Technology 2005 Japanese Ministry of Economy, Trade and Industry Low Rise Industrial Source Dispersion Model METI-LIS Model Ver 2.02 Operation Manual 87 pp p 87

https://www.aist-riss.jp/projects/METI-LIS/20050630METI-LIS%20Operation%20Manual.pdf

Therefore, the use of METI-LIS in non-simple terrain, such as when elevation of land

surrounding a polluting facility is higher than the facility’s stack, is beyond the scope of how METI-LIS can be used VAPCO’s wrong choice of a pollutant dispersion model is the reason why predicted air pollutant concentrations presented in the 2018 EIA Report do not reflect the well-known effect of how nearby higher elevations trap air pollution plumes emitted by stacks See, for example, Figure 3.5 of the 2018 EIA Report (below), which shows the absence of any impact

of the nearby higher elevations on predicted annual levels of PM10.12

Figure 3 5- Annual PM 10 concentrations in the scenario of normal operation of VA2 Plant

In our opinion, it is implausible that nearby higher elevations would have no impact on levels of

PM10 The wrong choice of METI-LIS as a model renders meaningless the predictions of air quality impacts presented in the EIA In our opinion, the wrong choice of an air pollutant

dispersion model in this instance substantially underestimates pollutant levels during periods of time when winds are calm, and shortly after sunrise when cooler sea and land surfaces reduce the height of mixing layer into which pollution plumes from a stack can disperse

3 Emission standards for the project are significantly weaker than equivalent

international ones

According to the 2018 EIA Report at page 148, the proposed Vung Ang II Thermal Power Plant would comply with the following Vietnamese emissions standards: a limit of 50 mg/Nm3 for emissions of PM10; a limit of 200 mg/Nm3 for emissions of SO2; and a limit of 455 mg/Nm3 for emissions of NOx.

12 2018 EIA Report, Chapter 3, p 163

These emissions standards are substantially weaker than those required internationally, including by the European Union, which require adherence to the following limits for new coal-fired power plants larger than 300 MW: a limit of no more than 5 mg/Nm3 for emissions of

PM10; a limit of no more than 75 mg/Nm3 for emissions of SO2; and a limit of no more than 85 mg/Nm3 for emissions of NOx on a yearly average basis.13

13 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control)

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010L0075&from=EN

4 The proposed manner of handling coal combustion residuals violates IFC guidelines

The wet disposal of coal combustion residuals (fly ash and bottom ash) vastly increases the environmental footprint of a coal-fired power plant Wet disposal of ash: 1) wastes water; 2) creates potential fugitive sources of particulate matter from portions of the ash disposal site that dry out; 3) creates the potential for groundwater and surface water contamination by contaminants that can leach from the ash disposal site; and 4) creates a risk to public safety if the ash disposal site containment fails or is flooded

Google Earth satellite images of the Vung Ang I power plant reveals a wet ash disposal site with

a considerable environmental footprint, covering an area of more than 20 hectares

For this reason, international best practice dictates that wet handling of ash be avoided According to the IFC:

“Recommended water treatment and wastewater conservation methods are discussed

in Sections 1.3 and 1.4, respectively, of the General EHS Guidelines In addition,

recommended measures to prevent, minimize, and control wastewater effluents from thermal power plants include:

[…]

• “Collection of fly ash in dry form and bottom ash in drag chain conveyor systems

in new coal-fired power plants; ….”14

14 International Finance Corporation 2008 Environmental, Health, and Safety Guidelines for Thermal Power Plants 33pp p 11

https://www.ifc.org/wps/wcm/connect/f82a5f06-f3f7-4033-8ea6-b767523cda8e/FINAL_Thermal%2BPower.pdf?MOD=AJPERES&CVID=jqeD9Eg&id=1323162579734